Part 21 Report - 1997-811

ACCESSION #: 9711030183 ABB October 30, 1997 LD-97-031 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555 Subject: Report Pursuant to 10 CFR 21 Regarding Incorrect Nut And Washer Plate Material for ECCS Suction Strainer Bolted Connections Gentlemen: The purpose of this letter is to notify the Nuclear Regulatory Commission of a defect pursuant to 10 CFR 21, "Reporting of Defects and Noncompliance." The identified "defect" is the use of incorrect material in the fabrication of nut plates and washer plates for Peach Bottom Unit 3 Emergency Core Cooling System (ECCS) suction strainer bolted connections. The nut plates and washer plates were fabricated from incorrect material and delivered to the Peach Bottom Unit 3 site. US Tool and Die Company fabricated the parts as a subvendor to ABB-CE. During receipt inspection by Philadelphia Electric Company (PECO), it was determined that the nut plates and washer plates were fabricated with SA-240, Type 304 material instead of the specified 17-4 PH material, SA-564, SA-693, or SA-705, Grade 630 in H1150 condition per ASME Code Section III, Class 1, Subsection NF, 1989 Edition, no addenda. These parts are used as part of the bolted connection when two or more strainer modules are joined together to form a strainer train. High strength bolts are threaded into the nut plates and torqued to a level that results in a bolt preload that exceeds required operational bolt loads. This assures that the strainer train remains continuous for all loading cases, and that no unacceptable gaps develop between strainer modules. The SA-240, Type 304 material has lower yield and tensile properties than the specified material. These nut and washer plates were never installed, and replacement parts have been provided which have the required material properties. This is the first application of this design and, therefore, no previous applications exist. ABB Combustion Engineering Nuclear Operations Combustion Engineering, P.O. Box 500 Telephone (203) 688-1911 Inc. 1000 Prospect Hill Road Fax (203) 285-9512 Windsor, Connecticut 06095-0500 LD-97-031 Page 2 An evaluation was performed to determine the potential conditions that might have existed if this material discrepancy had not been discovered and the parts fabricated of incorrect material had been installed in the strainers. Three potential conditions could have existed. 1. The threads in the SA-240 Type 304 nut plates would have been subjected to shear forces that exceed the ASME code allowable values. The threads may have sheared during the installation torquing process, in which case the material discrepancy would have been discovered prior to plant operation. 2. The threads in the SA-240 Type 304 nut plates would have locally yielded and strain hardened, but would have held the applied torque and resulting bolt preload. The preload was specified at a level that exceeds specified operational loadings up to and including Level D loadings. Since the temperature at operation is well below the threshold for creep relaxation, the bolt preload would remain as intended during use. Shop testing by US Tool and Die Company indicates that this is the most likely result. 3. During installation at high torque values, some SA-240, Type 304 threads may have yielded and galled. Galling of the threads during installation could result in a failure to achieve the design bolt preload, even though the proper torque is applied. The propensity for galling of these incorrect materials is about the same as for the specified materials for lower torque values. It is the greater potential for local yielding at high torque values that increases the risk of galling of the incorrect materials in this application. Failure to achieve the proper bolt preload could result in the strainer modules separating by more than the design limit of 1/8 inch during some loading cases. It should be noted that shop torque testing at US Tool and Die Company of nut and washer plates fabricated from the incorrect materials did not result in galling at torque values equal to or higher than that prescribed. The Attachment contains information specifically required by 10 CFR 21. Very truly yours, COMBUSTION ENGINEERING, Inc. Ian C. Rickard, Director Operations Licensing cc: M. F. Barnoski (ABB-CE) Attachment to LD-97-031 1 ABB Combustion Engineering Nuclear Operations 10 CFR 21 Report of a Defect or Failure to Comply The following information is provided pursuant to 10 CFR 21.21 (c)(4): (i) Name and address of the individual informing the Commission: Ian C. Rickard, Director Operations Licensing Combustion Engineering 2000 Day Hill Road Windsor, CT 06095-0500 (ii) Identification of the facility, the activity, or the basic component supplied for such facility or such activity within the United States which fails to comply or contains a defect: The basic components are nut plates and washer plates for ECCS suction strainer bolted connections. (iii) Identification of the firm constructing the facility or supplying the basic component which fails to comply or contains a defect: The nut plates and washer plates were supplied to ABB-CE by US Tool and Die Company, and were subsequently provided to the nuclear plant identified in item (vi) below by: Combustion Engineering, Inc. 2000 Day Hill Road Windsor, CT 06095-0500 (iv) Nature of defect or failure to comply and the safety hazard which is created or could be created by such defect or failure to comply: The defect is the use of incorrect material in the fabrication of nut plates and washer plates used in ECCS suction strainer bolted connections. The incorrect material could result in failure to achieve proper bolt preload, potentially resulting in strainer modules separating by more than the design limit of 1/8 inch during some loading cases. 2 Attachment to LD-97-031 (v) The date on which the information of such defect or failure to comply was obtained: ABB-CE received information regarding incorrect nut plate and washer plate material on September 18, 1997. (vi) In the case of a basic component which contains a defect or fails to comply, the number and location of all such components in use at, supplied for, or being supplied for one or more facilities or activities subject to the regulations of this part: ABB-CE supplied 208 nut plates and 208 washer plates to PECO for use at Peach Bottom Unit 3. The incorrect material was discovered during receipt inspection by PECO, and the affected nut plates and washer plates were not installed. (vii) The corrective action which has been, is being, or will be taken; the name of the individual responsible for the action; and the length of time that has been or will be taken to complete the action: ABB-CE is preparing training classes to strengthen its own internal review processes to prevent a recurrence of this error. These training classes will be held by the end of December, 1997. US Tool and Die Company is currently revising its internal procedures to prevent a recurrence of this error. US Tool and Die Company has initiated a requirement that all contract material be receipt inspected in accordance with approved customer documents. (viii) Any advice related to the defect or failure to comply about the facility, activity, or basic component that has been, is being, or will be given to purchasers or licensees: ABB-CE intends to provide an information copy of this 10 CFR 21 report to PECO Energy, Stone and Webster Engineering Corporation, and utilities owning an ABB-CE designed NSSS. Within the scope of ABB CE's activities, this issue applies only to PECO Energy's Peach Bottom Unit 3. *** END OF DOCUMENT ***

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